CAMP OTX's December 2023 groundwater withdrawal requests for 1) a new Lower Trinity public water supply well and 2) an increase from their currently permitted annual withdrawal limit of 85 acre feet to 270 acre feet are still pending.
This significant increase in groundwater withdrawal was contested by Friends of Hondo Canyon and the City of Bandera; both organizations were granted legal standing in September, 2024. The Bandera County Groundwater and River Authority (BCRAGD) Board voted unanimously to have the merits of this large withdrawal request heard at the State Office of Administrative Hearings (SOAH). THE SOAH HEARING was held November 5-7, 2025. To summarize the proceedings:
Camp OTX presented 3 scientists supporting their claims, among others, that 1)the water from the Lower Trinity Aquifer was readily available for this amount of pumping without impinging on ability of other landowners from withdrawing groundwater and 2) the need for 120 Acre feet of water for irrigation was justified because of undisclosed plans to level hills, truck in dirt, and create pastures requiring irrigation.
Friends of Hondo Canyon and the City of Bandera then presented 3 scientists whose testimony provided that 1) this amount of groundwater drawdown would likely cause unreasonable negative impacts to neighboring properties from withdrawing water; 2) there is not a demonstrated need for 120 acre-feet of irrigation water given the applicant has provided no plan to overcome steep slopes, shallow bedrock, and poor soils, and 3) the application failed to consider available wastewater effluent which does not amount to an efficient use of groundwater.
The Bandera County River Authority and Groundwater District Manager then presented his review of the application, and provided 1 expert hydrologist who testified that the groundwater was not there to sustain long-term withdrawal of this amount of water without exceeding the “Desired Future Conditions” -- the maximum amount of groundwater drawdown recommended by the Texas Water Development Board for our region.
In this legal process, it is important for us all to understand the next steps.
First, we as citizens have been heard, as Friends of Hondo Canyon has represented us. It is now up to the lawyers representing RR 417 (Camp OTX), our lawyer representing Friends of Hondo Canyon and the City of Bandera, and the lawyers representing BCRAGD General Manager to summarize their respective witness testimonies and present them to the Judge (so called ‘Closing Arguments”), which will be submitted in writing to the Judge in early January 2026. Each party will be able to provide written responses in February 2026.
Then the SOAH Judge , after personally hearing all testimony during the past 3 days, and reviewing all the written arguments, will make a recommendation to the BCRAGD Board of Directors called a “Proposal for Decision (PFD).” This PFD will likely be issued in April 2026. The final decision for permitting is left to BCRAGD Board to determine. We will keep you updated as these events unfold and to alert you to the date of the final actions in this matter.
So, the process is in place and we must respect it and follow it. We thank you for following it with us, no matter how long it takes.
WANT MORE INFORMATION?
Background: In their application, RR 417 asked to more than triple the amount of ground water the Camp is currently permitted to withdraw.
The application states the increase in water is for planned camp expansion, accommodating 2,000 campers per day during their 10 week Summer Camp Season, as well as retreats/meetings for another 40 weeks of the year.
The Camp also requested that all water use be aggregated – meaning that once the water is withdrawn, it can be used for any purpose. Friends of Hondo Canyon is concerned that this request would allow Camp OTX to secure additional groundwater to fill additional, yet-to-be-constructed man-made lakes on the Camp property. To quote from their application:
“Water is to be used for consumption at Camp OTX, for commercial purposes, irrigation (as needed), it will be plumbed into the PWS Water Supply maintained at Camp OTX, and may also be used to provide water to fill impoundments necessary for Camp OTX operation.”
TCEQ has already estimated that in a ‘bad year’ nearly 100% of the groundwater that is used to fill their existing 2 lakes could be lost to evaporation. Friends of Hondo Canyon does not feel that the business decision of RR 417 to locate and invest millions of dollars into Camp OTX in Hondo Canyon confers any right to excessively withdraw water from our stressed aquifers. Bandera County has limited groundwater resources, and this shared resource must be equitably proportioned to all.
This significant increase in groundwater withdrawal was contested by Friends of Hondo Canyon and the City of Bandera; both organizations were granted legal standing in September, 2024. The Bandera County Groundwater and River Authority (BCRAGD) Board voted unanimously to have the merits of this large withdrawal request heard at the State Office of Administrative Hearings (SOAH). THE SOAH HEARING was held November 5-7, 2025. To summarize the proceedings:
Camp OTX presented 3 scientists supporting their claims, among others, that 1)the water from the Lower Trinity Aquifer was readily available for this amount of pumping without impinging on ability of other landowners from withdrawing groundwater and 2) the need for 120 Acre feet of water for irrigation was justified because of undisclosed plans to level hills, truck in dirt, and create pastures requiring irrigation.
Friends of Hondo Canyon and the City of Bandera then presented 3 scientists whose testimony provided that 1) this amount of groundwater drawdown would likely cause unreasonable negative impacts to neighboring properties from withdrawing water; 2) there is not a demonstrated need for 120 acre-feet of irrigation water given the applicant has provided no plan to overcome steep slopes, shallow bedrock, and poor soils, and 3) the application failed to consider available wastewater effluent which does not amount to an efficient use of groundwater.
The Bandera County River Authority and Groundwater District Manager then presented his review of the application, and provided 1 expert hydrologist who testified that the groundwater was not there to sustain long-term withdrawal of this amount of water without exceeding the “Desired Future Conditions” -- the maximum amount of groundwater drawdown recommended by the Texas Water Development Board for our region.
In this legal process, it is important for us all to understand the next steps.
First, we as citizens have been heard, as Friends of Hondo Canyon has represented us. It is now up to the lawyers representing RR 417 (Camp OTX), our lawyer representing Friends of Hondo Canyon and the City of Bandera, and the lawyers representing BCRAGD General Manager to summarize their respective witness testimonies and present them to the Judge (so called ‘Closing Arguments”), which will be submitted in writing to the Judge in early January 2026. Each party will be able to provide written responses in February 2026.
Then the SOAH Judge , after personally hearing all testimony during the past 3 days, and reviewing all the written arguments, will make a recommendation to the BCRAGD Board of Directors called a “Proposal for Decision (PFD).” This PFD will likely be issued in April 2026. The final decision for permitting is left to BCRAGD Board to determine. We will keep you updated as these events unfold and to alert you to the date of the final actions in this matter.
So, the process is in place and we must respect it and follow it. We thank you for following it with us, no matter how long it takes.
WANT MORE INFORMATION?
Background: In their application, RR 417 asked to more than triple the amount of ground water the Camp is currently permitted to withdraw.
The application states the increase in water is for planned camp expansion, accommodating 2,000 campers per day during their 10 week Summer Camp Season, as well as retreats/meetings for another 40 weeks of the year.
The Camp also requested that all water use be aggregated – meaning that once the water is withdrawn, it can be used for any purpose. Friends of Hondo Canyon is concerned that this request would allow Camp OTX to secure additional groundwater to fill additional, yet-to-be-constructed man-made lakes on the Camp property. To quote from their application:
“Water is to be used for consumption at Camp OTX, for commercial purposes, irrigation (as needed), it will be plumbed into the PWS Water Supply maintained at Camp OTX, and may also be used to provide water to fill impoundments necessary for Camp OTX operation.”
TCEQ has already estimated that in a ‘bad year’ nearly 100% of the groundwater that is used to fill their existing 2 lakes could be lost to evaporation. Friends of Hondo Canyon does not feel that the business decision of RR 417 to locate and invest millions of dollars into Camp OTX in Hondo Canyon confers any right to excessively withdraw water from our stressed aquifers. Bandera County has limited groundwater resources, and this shared resource must be equitably proportioned to all.
Camp OTX is our neighbor. Friends of Hondo Canyon is not against the Camp or its mission, but we are concerned about the quality and quantity of water available in Hondo Canyon. We have asked for transparency. A 'blank check' for groundwater withdrawal whose use is neither documented nor explained in their application does not qualify as transparent.
